Scope of judicial review in departmental inquiries is limited to the decision-making process, not the merits.

The petitioner, while serving as a Laboratory Technician/Cashier at Government Kamla Raja Girls PG College, was charged with financial irregularities and defalcation of Rs. 7,20,460/-, as well as failing to deposit daily cash transactions

Following a regular departmental inquiry under the MP Civil Services (CCA) Rules, 1966, the disciplinary authority dismissed him from service and ordered a recovery of Rs. 1,80,115/- on February 28, 2018

On appeal, the respondent No. 1 modified the penalty on March 15, 2019, reinstating the petitioner but imposing the withholding of two annual increments with cumulative effect and denying back wages for the period of termination based on the principle of "no work no pay"

The petitioner challenged both the original dismissal and the modified appellate order via this writ petition under Article 226 of the Constitution

1. Whether the appellate authority erred in imposing a modified penalty of withholding increments and denying back wages despite reinstating the petitioner

2. Whether the departmental inquiry and subsequent penalty were subject to judicial review under Article 226 based on the procedural fairness of the decision-making process

Rule 14 of the MP Civil Services (Classification, Control and Appeal) Rules, 1966, regarding the procedure for imposing major penalties

State of Karnataka v. N. Gangraj (2020) 3 SCC 423, which establishes that judicial review under Article 226 is confined strictly to the "decision-making process" rather than the merits of the decision itself

State of A.P. v. S. Sree Rama Rao, AIR 1963 SC 1723, affirming that a High Court does not sit as a court of appeal over departmental inquiries and cannot re-appreciate evidence if the conclusion is supported by some evidence and follows natural justice

The Court found that the inquiry officer strictly adhered to the procedural requirements of Rule 14 of the 1966 Rules and provided the petitioner with a full opportunity to present his defense

Applying the N. Gangraj doctrine, the Court noted that its role is limited to checking for infirmities in the process rather than questioning the proportionality of the punishment

The Court observed that the charges involved serious financial misappropriation of government funds and that the appellate authority had already exercised leniency by setting aside the dismissal and recovery orders

Since the decision-making process was found to be legally sound and the petitioner was also facing criminal prosecution under Section 408 of the IPC for the same incident, the Court determined there was no ground for further intervention

The Court dismissed the petition, upholding the modified penalty of withholding two annual increments with cumulative effect and the denial of wages for the period of termination